5 Key Takeaways | 2024 Emerging Trends: Delaware Unclaimed Property VDA and Multistate Audits
Common Scenarios Triggering False Claims Act Violations, Part 3: Claims and Investigations
Compliance Tip of the Day: Machine Learning for Internal Audit
DE Under 3: OFCCP Changes Up Important Technical Details of its Audit Selection Process in First FY 2024 CSAL
Preparing for a Government Healthcare Audit
What Can A Tax Attorney Do For You? A Podcast With Janathan Allen
Navigating GSA Audits Compliance Strategies and Best Practices
DE Under 3: US DOL Inspector General’s Office Plans to Review Effectiveness of OFCCP Compliance Evaluations
DE Under 3: What Federal Contractors Need to Know About OFCCP's New Audit Scheduling Letter
DE Under 3: What’s New in OFCCP’s Latest Audit Scheduling Letter for Supply & Service Contractors
Independent Audits of Nonprofit Organizations With Douglas Cook
DE Under 3: U.S. OPM Proposed Allowing Federal Managers To Avoid Most Qualified Candidates To Pick Those Who Offer Better “Fit”
AGG Talks: Home Health & Hospice - Reimbursement Audits and Appeals
After ALJ: Options and Opportunities in the Face of an Unfavorable ALJ Decision
The Presumption of Innocence Podcast: Episode 21 - Conservation Easement Donations: Tax Shelter or Charitable Contribution Deduction?
Compliance and Managing from the Middle
I Understood There Would Be No Math: Audits, Extrapolations, and a New Set of Rules
JONES DAY PRESENTS®: Trade Secret Audits: Enhanced Mapping, Protecting Access and Creating Understanding
Constangy Webinar - DEI Audits: Tools to Enhance Your DEI Practices
[Podcast] New Year, New PAC: Have a Successful PAC Audit in 2023
The following newsletter provides a roundup summarizing enforcement actions, guidance, rulemakings, and other public statements taken by a federal and/or state financial services regulatory agency, specifically focusing on:...more
Public companies should prepare for a more strenuous auditing process, and the increased likelihood that the information that they share with their auditors could be compelled by the Securities and Exchange Commission (SEC)...more
The unprecedented challenges created by the COVID-19 pandemic and resulting government lockdowns could strain even the most robust compliance programs. Companies have been appropriately focused on business preservation during...more
In the News. The Securities and Exchange Commission (SEC) announced that it adopted Rule 12d1-4 under the Investment Company Act of 1940 (the 1940 Act), providing a new regulatory framework for fund-of-funds and final...more
On Friday, July 17, 2020, Special Inspector General for Pandemic Recovery (SIGPR) Brian D. Miller and U.S. Attorney for the Eastern District of Virginia (EDVA) G. Zachary Terwilliger announced a formal partnership to pursue...more
While gearing up to get trillions of dollars into the economy, the government was also setting in place the mechanism to investigate and prosecute fraud related to these programs. The CARES Act was signed into law on March...more
We are pleased to present our annual mid-year update on financial reporting and issuer disclosure enforcement activity for 2019. This White Paper primarily focuses on the U.S. Securities and Exchange Commission's enforcement...more
On May 2, 2019, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued guidance titled “A Framework for OFAC Compliance Commitments” (Guidance), providing direction regarding what OFAC considers to...more
In light of the evolving (or evolved) DOJ and SEC approach to FCPA enforcement in the merger and acquisition context, global companies have to emphasize their post-acquisition process. ...more
On November 29, 2017, Deputy Attorney General Rod Rosenstein announced that the U.S. Department of Justice (DOJ) was issuing a new enforcement policy covering its enforcement of the Foreign Corrupt Practices Act (FCPA). The...more
For a company under actual or potential government scrutiny, an independent internal investigation performed by outside counsel, sometimes coupled with cooperation with the government, can mean the difference between...more
I recently had the chance to visit with Joe Howell, the Executive Vice President of Workiva LLC, to discuss, among other things, the function of the Public Companies Accounting Oversight Board (PCAOB) and what role it might...more
This week I have been exploring the different types compliance committee’s which an organization can utilize to help effect a best practices compliance program. I have written about compliance committee’s at the Board of...more
Federal District Court Approves Flash Crash Spoofer’s US $38 Million Settlement; Federal Appeals Court Appears Sympathetic to Michael Coscia’s Claim That Spoofing Prohibition Is Too Vague - The US federal court handling...more
This week I have been exploring the Public Accounting Oversight Board (PCAOB) with Joe Howell, an Executive Vice President (EVP) with Workiva Inc. We have considered how some of the issues addressed by the PCAOB directly...more
The Yates Memo, refocusing DOJ criminal and civil corporate investigations, continues to be the critical topic of discussion this week. The Memo, discussed here, directs that individuals be the focus of the inquiry from the...more
Today we celebrate innovation. On this day in 1873, a patent to create work pants reinforced with metal rivets was granted. This marked the birth of one of the world’s most famous garments: the blue jeans. Jacob Davis, a...more
Explore new approaches to third party audits for a more effective, risk-aligned third party risk management program. Compliance officers have been insisting on (and should continue to insist on) including third party...more
The Commission brought two FCPA cases this week, one of which was in conjunction with the DOJ. Both centered on the payments for gifts and travel in China. In addition, the SEC filed three manipulation cases, an action...more
A new service, Snapchat, has joined the constellation of social media services with potential business implications. Snapchat is a mobile application, originally aimed at teenagers, which allows users to send photos and text...more
The recent examples of compliance program credits for Morgan Stanley and Ralph Lauren have demonstrated that, more than ever, an effective compliance program can protect a company from criminal indictment and generate bottom...more
The Foreign Corrupt Practices Act ("FCPA" or "the Act") prohibits bribery of foreign public officials in order to obtain or retain business. In addition to its anti-bribery provisions, the FCPA contains accounting provisions...more
The Justice Department and the SEC should be credited with promoting new compliance strategies and best practices. Whatever you may think about the DOJ/SEC FCPA enforcement program, they have pushed businesses to enhance...more
Audit committees must aid management in navigating an increasingly complex regulatory framework. Two recent developments arising from the passage and implementation of the Dodd-Frank Act have led to further challenges for...more
As we welcome in 2013, it is appropriate to reflect back on some of the things which have occurred over 2012 and in the Foreign Corrupt Practices Act (FCPA) enforcement world, it was quite a significant year. The Department...more